DCT
2:17-cv-00199
LGRT Pro LLC v. Linen 'N Things Center Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LGRT PRO LLC (Texas)
- Defendant: LINENS 'N THINGS CENTER, INC. (New Jersey)
- Plaintiff’s Counsel: Zimmerman Law Group
- Case Identification: 2:17-cv-00199, D.N.J., 01/11/2017
- Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant is a New Jersey corporation with its principal office in the district, conducts substantial business there, and a portion of the alleged infringement occurred in the district.
- Core Dispute: Plaintiff alleges that Defendant’s e-commerce website checkout system infringes a patent related to a method of document assembly that uses "live data fields" to automatically populate and update information.
- Technical Context: The technology at issue involves methods for managing data consistency across different fields within a single electronic document or across multiple related documents, a common challenge in document preparation and data entry systems.
- Key Procedural History: The complaint does not mention prior litigation, IPR proceedings, or licensing history related to the patent-in-suit. The complaint does assert that the patent claims are limited by their corresponding disclosures in the specification and prosecution history under 35 U.S.C. § 112, which may suggest a strategy to preemptively address potential validity or indefiniteness challenges.
Case Timeline
| Date | Event |
|---|---|
| 2000-06-06 | U.S. Patent No. 6,895,554 Priority Date (Provisional App.) |
| 2005-05-17 | U.S. Patent No. 6,895,554 Issued |
| 2017-01-11 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 6,895,554, “Method of Document Assembly,” issued May 17, 2005 (the "’554 Patent").
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional word processors treat all entered data as simple words or symbols, unable to recognize their underlying properties (e.g., distinguishing "John Smith" as a proper name versus a generic group of words). This necessitates manual, repetitive "search-and-replace" operations to ensure consistency within a single document or across multiple related documents (’554 Patent, col. 1:12-29).
- The Patented Solution: The invention proposes a method where "live data fields" in a document are associated with data stored in a database. This is achieved by assigning a unique key to each live data field, which links the field to corresponding records in database tables that store the data and its attributes (’554 Patent, col. 1:55-62; col. 3:40-51). When data in one live field is changed, the system uses these linked records to automatically update other instances of the same field, either within the same document or in different but related documents, thereby maintaining data integrity without manual intervention (’554 Patent, col. 1:44-54).
- Technical Importance: The complaint alleges that this approach represents a technological improvement over generic computers by enabling the automatic, simultaneous population and editing of data across multiple live fields without requiring manual duplication (Compl. ¶12, 14).
Key Claims at a Glance
The complaint asserts infringement of "one or more claims" of the ’554 patent without specifying them (Compl. ¶18). The first independent claim is Claim 1.
- Independent Claim 1:
- (a) initializing or opening in a memory of a computer a document having at least one live data field;
- (b) initializing a record in the memory for each live data field, each record storing an attribute or property of data received in the corresponding live data field;
- (c) inserting data into a first live data field or amending data in the first live data field; and
- (d) inserting data into a second live data field or amending the data in second live data field to include the data inserted into or amended in the first live data field based on the attributes or properties of the data stored in the records of the first and second live data fields.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant's "computer implemented system" for assembling an electronic document, which is identified as an "integral part of Defendant's https://www.lnt.com/Checkout electronic commerce website" (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the website's checkout process infringes. Specifically, it describes a system where a customer provides billing and/or shipping information into form fields. The system allegedly uses data entered into a "first data field" (e.g., a billing address field) to populate a "second live data field" (e.g., a shipping address field) based on the type of information being stored (Compl. ¶18).
- The complaint does not provide further technical details on the operation of the checkout system but frames it as a core component of Defendant's e-commerce operations. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'554 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) initializing or opening in a memory of a computer a document having at least one live data field; | The system opens or initializes a document (the checkout page) with at least one live data field for customer billing and/or shipping information. | ¶18 | col. 11:7-9 |
| (b) initializing a record in the memory for each live data field, each record storing an attribute or property of data received in the corresponding live data field; | The system initializes a record in computer memory for each live data field. | ¶18 | col. 11:10-13 |
| (c) inserting data into a first live data field or amending data in the first live data field; | The system inserts user-provided data, such as shipping and/or billing information, into a first data field. | ¶18 | col. 11:14-16 |
| (d) inserting data into a second live data field or amending the data in second live data field to include the data inserted into or amended in the first live data field based on the attributes or properties of the data stored in the records of the first and second live data fields. | The system inserts data from the first live data field into a second live data field (e.g., populating a shipping address from a billing address) based on the type of information, such as name, address, etc. | ¶18 | col. 11:17-22 |
Identified Points of Contention
- Scope Questions: A primary question will be whether an interactive e-commerce checkout webpage constitutes a "document" within the meaning of the claims. The patent specification repeatedly refers to word processing software like Microsoft Word and document templates, which may suggest a narrower scope than a dynamic web form (’554 Patent, col. 3:17-21).
- Technical Questions: The infringement allegation hinges on whether the accused website's functionality for populating one form field from another (e.g., "shipping same as billing") operates by "initializing a record...storing an attribute or property of data" as required by claim 1(b) and detailed in the patent's specification. The complaint does not provide evidence of the specific back-end architecture, raising the question of whether the accused system uses the claimed database and record-linking structure or a different, more conventional web-form technology.
V. Key Claim Terms for Construction
The Term: "document"
Context and Importance
The applicability of the patent to the accused e-commerce website depends entirely on whether a webpage is considered a "document." Defendant may argue the term is limited to the word-processing context described in the specification, while Plaintiff will likely argue for a broader definition encompassing any electronic file that assembles information.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The term "document" is used generally throughout the claims and summary, and the problem addressed—data consistency—is not inherently limited to word processors. The method is described as one of "document assembly" in the abstract, a potentially broad concept.
- Evidence for a Narrower Interpretation: The detailed description explicitly grounds the invention in the context of a "word processor, particularly Microsoft® Word 97" (’554 Patent, col. 3:17-19) and discusses creating documents from "template[s] which includes predetermined words, characters, symbols, and the like" (’554 Patent, col. 2:13-16), which may support limiting the term to static or template-based files.
The Term: "live data field"
Context and Importance
Practitioners may focus on this term because infringement requires the accused system to use not just any data field, but a "live data field" that is linked to a "record" storing its "attributes or properties." The dispute will likely center on whether the accused website's form fields meet this specific architectural requirement.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language itself does not impose extensive structural limitations on the term. Plaintiff may argue any field that can be automatically populated or updated based on another field's data qualifies.
- Evidence for a Narrower Interpretation: The specification describes a specific implementation where a live data field is associated with a "globally unique key," a "first table," a "second table," and a "Custom Property Object (CPO)" (’554 Patent, col. 1:55-62; col. 5:40-50). Defendant may argue that a "live data field" must be part of this disclosed architecture to fall within the claim scope.
VI. Other Allegations
Indirect Infringement
The complaint alleges active inducement under 35 U.S.C. § 271(b), asserting that Defendant knowingly and intentionally encourages its customers and employees to use the allegedly infringing system through its e-commerce website (Compl. ¶19).
Willful Infringement
Willfulness is alleged based on Defendant's knowledge of the ’554 patent "at least as early as the date Plaintiff's Complaint for Patent Infringement was filed" (Compl. ¶20). The complaint further alleges that Defendant's continued operation of its website constitutes an "objectively high likelihood of infringement" and that, on information and belief, Defendant has not obtained an opinion of counsel regarding the patent (Compl. ¶22, 23).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case appears to depend on the answers to two central questions:
- A core issue will be one of definitional scope: Can the term "document", which is described in the patent's specification in the context of word processors and file templates, be construed broadly enough to encompass an interactive e-commerce checkout webpage?
- A key evidentiary question will be one of technical implementation: Does the accused website's functionality for auto-populating form data (e.g., shipping from billing) rely on the specific architecture of linked records, tables, and unique keys that define a "live data field" in the ’554 patent, or does it use a different, unpatented method to achieve a similar result?